It would seem that under PSLRA the judge is limited to attorney's fees and expenses when it comes to sanctions. But Rule 11 apparently allows the judge to levy additional "punitive" amounts necessary to "deter" the offensive conduct in the future? See the case below...

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The judge ordered the three Prenda attorneyfs to pay sanctions to defense attorneys of $36,150 to Morgan Pietz and $1,950 to Nicholas Ranallo. Wright then doubled that amount “as a punitive measure” for a total of $81,319.72. The judge says in a footnote that the total “is calculated to be just below the cost of an effective appeal”. The Prenda attorneys have 14 days to pay the sanctions.

Wright is also suggesting that the attorneys be disbarred. He states that, “there is little doubt that Steele, Hansmeier, Duffy [and] Gibbs suffer from a form of moral turpitude unbecoming an officer of the court.” In many states, California included, crimes reaching the level of “moral turpitude” lead to automatic disbarment. Wright says that he will be referring the four lawyers to every state bar in which they are currently admitted to practice.

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http://www.chicagobusinesslitigationlawyerblo...s_are.html

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Sullivan has asked the Judge to award sanctions based on the PSLRA (reasonable attorneys’ fees and other expenses incurred in the action) versus the Rule 11 sanctions (which must be limited to what suffices to deter repetition of the conduct). - LR

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